Professional Documents
Culture Documents
Back Injuries:
Improving Lifting Decisions
& Reducing Back Pain
in Your Workforce
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EDITORIAL
Managing Editor
continues with perspectives on LOTO that STEPHEN D. BRUCE, PHD, PHR
sbruce@blr.com
will help any employer improve its program.
EVELYN SACKS
Please read these articles, and be sure your eviesacks@gmail.com
lockout/tagout 1910.147 procedures are in JENNIFER BUSICK
jenbusick@sff.net
place and are rigorously observed. JASMIN ROJAS, JD
Elsewhere in this issue, regular colum- jrojas@blr.com
nist Ray Prest adds his take on LOTO. He CLARE CONDON
clarecondon@sbcglobal.net
notes that while the process, when followed ANA ELLINGTON
faithfully, has a remarkable success rate at aellington@blr.com
L
Production Editor
if the shoe fits—don’t charge for it! She re- JAMES K. DAVIS
jdavis@blr.com
ockout/tagout (LOTO) is one of views a case involving impermissible work-
Proofreaders
the most effective tools for pre- ers’ compensation employee contributions. DEBBIE FLYNN
venting serious—and often grue- Need to know a little more about OSHA’s dflynn@blr.com
JOAN CARLSON
some—accidents. Unfortunately, to new procedures when reporting severe in- jcarlson@blr.com
some short-sighted supervisors, it juries and rapid response investigations? LINDA COSTA
lcosta@blr.com
appears to be a productivity killer, BLR Legal Editor and safety specialist Ana
BRECHIN KNAPP
so they try to get by without it. But Ellington clarifies the new guidelines. bknapp@blr.com
nothing kills productivity like an accident, Meanwhile, what else is in store in this
and circumventing LOTO procedures is issue? ART
Design Services Director
begging for trouble. • ‘But It Came That Way’—The Roles, VINCENT SKYERS
vskyers@blr.com
Responsibilities, and Accountability of
A welder was crushed to death by a hydrau- Machine Guarding Art Director
DOUG PONTE
lic door on a scrap metal shredder. He was • Incentivizing Safety: How Companies dponte@blr.com
trying to remove a jammed piece of metal Are Linking CEO Bonuses to EHS Goals Illustrators
from the door. • Preventing Employee Chemical Expo- KELLY CHURCH
kchurch@blr.com
sure at the Source RJ CLARKE
A mechanic was fatally crushed in an esca- rclarke@blr.com
VINCENT SKYERS
lator while performing maintenance. He had Plus, Keeping Up brings you another vskyers@blr.com
removed the escalator stairs and crawled round of ten timely items in safety news.
inside the escalator mechanism. When a As always, please share your comments MARKETING AND
OPERATIONS
coworker dropped the escalator’s electrical about the magazine—in general or any of Marketing Manager
circuit box, it triggered a relay that sent the articles—and please let me know what AMANDA HURLBURT
ahurlburt@blr.com
power to the escalator. you want to read about next. Several read-
ers have sent in some great ideas that we’re Marketing Associate
KATE DALY
These grizzly examples are typical of the working on for future issues. kdaly@blr.com
estimated 150–200 fatalities (and 50,000 or Marketing Operations Assistant
MICHELLE DEFRANCESCO
so injuries) that occur each year due to a Thanks for reading, mdefrancesco@blr.com
failure to control the release of hazardous
energy. In this issue of Safety Decisions, SALES
Sales Manager
Contributing Editor Evie Sacks takes a PAUL MANKO
fresh look at LOTO, offering expert advice pmanko@blr.com
on how to manage your program, where Sales Associate
RYAN VINCENT
to go for detailed guidance, and what the Stephen D. Bruce, PhD, PHR rvincent@blr.com
Occupational Safety and Health Adminis- Managing Editor Copyright 2016 BLR®—
tration (OSHA) expects of employers. She sbruce@blr.com Business & Legal Resources
OSHA PENALTIES
increased to provide a real disincen-
tive for employers accepting injuries
and worker deaths as a cost of doing
will no longer count the number of inspections it conducts multiemployer worksites, workplace violence cases, and
(which, in case anyone is counting, is about 40,000 per others that require more in-depth analysis.
year). Under what it’s calling an Enforcement Waiving Sys- The agency will continue its use of the General Duty
tem, OSHA will no longer tally inspections, but will con- Clause (GDC) even in cases where a standard exists but
centrate on the more complicated, time-consuming cases. an employer could have provided more protections for its
“I think you’ll see more complex inspections, and I employees. Under GDC, employers are required to provide
think those end up being the more impactful inspections,” employees with a safe and healthful place of employment.
TRACKS TOXIC port for various causes, have a porous surface that mimics
a cell that absorbs the contaminants people are exposed to
they’ve been exposed. Measuring contact with toxins can wristbands, which showed exposure to polycyclic aromat-
be difficult, requiring expensive and bulky devices that ic hydrocarbons—12 of which are on the Environmental
people are reluctant to wear for long periods of time. Protection Agency’s priority list.
Oregon State University (OSU) says it has come up with The bracelets are not yet available to the public, but
a more accessible method that uses silicone bracelets to additional studies are planned.
slightly to let in air. Make sure snow is not blocking the exhaust pipe.
• While sitting, keep moving arms and legs to improve circulation and stay Keeping Up is compiled by Evelyn
warmer. Sacks, a contributing editor of Safety
• Do not eat unmelted snow, as it will lower your body temperature. Decisions. eviesacks@gmail.com
• Huddle with others, if anyone else is around, for warmth. Reprint: SD_0116-1
Lockout/Tagout:
Don’t Flip Out over
LOTO Compliance
Update your understanding of this
life- and limb-saving standard.
By Evelyn Sacks
A
welder was crushed to death by a hydraulic door on a scrap met-
al shredder. He was trying to remove a jammed piece of metal
from the door. The system’s energy had not been released, and
the door had not been blocked open.
A mechanic was fatally crushed in an escalator while per-
forming maintenance. He had removed the escalator stairs and
crawled inside the escalator mechanism. When a coworker
dropped the escalator’s electrical circuit box, it triggered a relay that sent power
to the escalator. The stairs began moving, and the mechanic could not escape.
The escalator had no locks or tags on any power controls.
These grizzly examples are typical of the estimated 150–200 fatalities (and
50,000 or so injuries) that occur each year due to a failure to control the release
of hazardous energy. Lockout/tagout (LOTO) 1910.147 refers to the Occupa-
tional Safety and Health Administration (OSHA)-required practices and proce-
dures to protect workers from unexpected start-up of machinery or from haz-
ardous energy released during service or maintenance. The standard is based on
the fact that simply turning equipment off is not enough to block stored energy.
Lockout devices hold energy-isolating equipment in a safe or off position.
They prevent equipment from becoming energized because the lockout devices
cannot be removed without a key or other unlocking mechanism. Tagout devices,
by contrast, are prominent warning devices that are fastened to energy-isolating
©ISTOCK.COM
devices to warn employees not to reenergize the machine while they are being
serviced or maintained. Tagout devices are easier to remove and, alone, provide
less protection than lockout devices.
If You’ve Got Equipment, the issue of “who’s covered” can be confusing. LOTO cov-
You’re Probably Covered ers servicing and maintenance of machines and equipment
According to OSHA, “If your employees service or main- where release of stored energy or unexpected startup could
tain machines where the unexpected startup, energiza- harm employees.
tion, or the release of stored energy could cause injury, She explains, “Normal production operations are not
the standard likely applies to you. The standard applies covered by the LOTO standard. However, servicing and/or
to all sources of energy including, but not limited to me- maintenance activities that take place during normal oper-
chanical, electrical, hydraulic, pneumatic, chemical, and ations are covered if an employee is required (1) to remove
thermal energy.” or bypass a guard or other safety device or (2) if an em-
Incidents related to the control of hazardous energy are ployee is required to place any part of his or her body into
perennially on OSHA’s top 10 list, but there seems to have an area on a machine or piece of equipment where work
been an uptick in cases in recent months. “One of the rea- is actually performed on the material being processed, or
sons we’re noticing so many amputations and related cita- where an associated danger zone exists during a machine
tions is OSHA’s new reporting rules that, since January, have operating cycle.”
required employers to notify the agency of all work-related
amputations,” explains Nickole Winnett, shareholder in the Understand the Exemptions
Washington, D.C., office of Jackson Lewis. The reporting LOTO does not apply to work on cord- or plug-connect-
serves as a red flag and is triggering more inspections. The ed electric equipment and certain hot tapping operations.
culprit behind amputations is often a failure to lock out or (Hot tapping refers to the installation of connections to
tag out hazardous energy when employees are working on pipelines while they remain in service.) Minor servicing
or near a machine, or a failure to use machine guarding. activities that take place during production are also not
Winnett says that although the standard is fairly straight- covered as long as the employer provides effective alterna-
forward and relatively easy for employers to understand, tive protection from hazardous energy, such as guards.
Compliant (and
• Exposure to electrical hazards from
work on equipment in electric utilization
installations;
Enviro.BLR.com is an online SPCC, SDWA and NPDES, and you. These are perfect tools
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28596-ENVIROBLR
E
nergy fuels enterprise.
Properly channeled and
managed, energy keeps
processes humming, equip-
ment producing, and plants
running. When released
uncontrolled, energy in
diverse forms—electrical, nuclear,
gravitational, thermal, and chemi-
cal among them—can injure or kill.
Hazardous energy releases may oc-
cur during installation, maintenance,
service, or repair of equipment or sys-
tems. The best way to avoid the risk is
to shut off power, lock out energy, re-
lease stored energy, and confirm that
it’s been done.
The Occupational Safety and
Health Administration’s (OSHA)
lockout/tagout (LOTO) standard re-
quires that equipment be locked or
tagged out of service when there is a
chance for injury. Personnel must not
attempt to operate switches, valves, or
other energy isolating devices once
they are locked or tagged. An autho-
rized person must turn off and dis-
connect equipment from its energy
source during service or maintenance.
Locks, tags, and other methods pre-
vent those who are unauthorized from
reenergizing equipment.
Lockout/tagout perennially ap-
pears on OSHA’s annual list of
most-violated standards. The agency
maintains that compliance could pre-
vent hundreds of deaths and thou-
sands of injuries, including ampu-
tations, each year. That’s why OSHA
continues to aggressively enforce this
bedrock standard.
Hazardous Energy
mation. With annual sales in excess of
$6 billion, the Milwaukee-based com-
pany helps customers in more than
80 countries achieve “smart, safe, sus-
Here are a few ideas that may change the way you think— tainable operations in a wide range of
and what you do—about lockout/tagout.
KELLY CHURCH
only be trained once (except in cases quick, on-the-floor session focused Evelyn Sacks is a contributing editor of
of job reassignment or new equip- on the equipment contractors will be Safety Decisions. eviesacks@gmail.com
ment), ESC Services and Rockwell working on. Reprint: SD_0116-3
S
Why Safety Culture afety is a topic that is uni-
versally shared. It is rare
A
Incentivizing Safety: t 9:47 pm on April 20,
2010, an explosion
to EHS Goals
ana in the Gulf of Mex-
ico. The explosion left 11 men dead,
17 workers injured, the rig destroyed
and sunk—and 3.19 million barrels
There has been a lot of controversy surrounding safety of oil spilled into the Gulf. The owner
incentives, and some programs are now targeting of the well, BP p.l.c., set aside almost
©ISTOCK.COM/CAMIJ
$54 billion to cover costs from the
executive compensation. But, is it a good idea? spill. The company’s top executive was
given no bonus that year. Since the ex-
By Jennifer Busick plosion, more than 90% of companies
correlation between linking executive metrics, it doesn’t appear that those answers should eventually come.
pay to EHS factors and worker safety. links have yet reached a level that has
Bloomberg noted that Chevron, which a measurable effect on worker safety Jennifer Busick is a contributing editor of
does not tie executive pay to measur- or environmental performance. Two Safety Decisions. jenbusick@sff.net
able safety metrics, had a recordable suggestions have been offered as to Reprint: SD_0116-5
I
f you wanted to summarize the an otherwise foolproof process—peo- on ensuring that workers have the
safety profession for a layperson, ple need to follow it for it to work. physical ability to lock out machin-
you would do well to start with As every safety professional quick- ery. But when it comes to dealing with
lockout/tagout (LOTO) as a great ly discovers, people have a frustrating decision-making issues, safety folks
example of the contemporary knack for not always following rules, tend to rely heavily on discipline. Un-
approach to workplace safety. It and it doesn’t matter how good a safe- fortunately, punishment is a relatively
combines an engineering solu- ty management system is if people ineffective tool because it doesn’t ac-
tion and a behavioral process in order don’t adhere to it. In many ways, it’s tually lead to more compliant behav-
to prevent workers from coming into safety’s biggest challenge: How else do ior. After all, if the possibility of dying
contact with hazardous energy. And, you get workers to follow rules when isn’t enough of a deterrent, it’s un-
if LOTO best practices are followed, they already know straying from safe- likely that receiving a scolding from
they can protect employees with an ty procedures puts them at a very real management will be effective. So rath-
impressive degree of reliability. But and very significant risk? er than concentrating our efforts on
RJ CLARK
like so many other aspects of work- A great deal of technological de- disciplining a failure to follow safety
place safety, there’s only one chink in velopment and training effort is spent rules, it’s more productive to focus on
what actually hinders employees from they found that the ability to think Decision fatigue explains why it’s
making safe decisions like following through a problem can be severely harder to stick to a diet after a long
LOTO procedures. compromised by both an individual’s day—our mental reserves have been
A burgeoning collection of research state of mind and the number of deci- depleted, and we have less energy to
suggests that decisions are affected sions he or she has had to make earlier stave off cravings. It’s the same with
by a number of factors and that our in the day. choosing whether to exercise. It gives
ability to make decisions is effectively If you’re struggling with LOTO at credence to something I hear fre-
limited. Two of the biggest names in your organization, you should reach quently from safety professionals:
decision research are Roy Baumeis- for your highlighter, because this is Workers are more lax with following
ter and John Tierney, who note in a crucial and woefully overlooked the rules towards the end of the work-
their book Willpower that a person’s contributor to workplace deaths: De- day, the end of a project, or the end
ability to exercise willpower declines cision fatigue plays an enormous role of the week. And, it could also point
with every decision he or she makes. in a worker’s ability to carry out the to why obvious procedures like LOTO
In experiment after experiment, proper LOTO process. can be overlooked.
GISTOCK.COM/VETKIT
T
If the Shoe Fits—
he Chipotle franchise is well known for its
“healthier” version of fast food. Indeed, its
A
Preventing Employee
s environment, health,
and safety (EHS) pro-
Chemical Exposure
fessionals, we all want
to make sure employ-
ees are at home with
“ALL WORKERS WHO ARE EXPOSED TO refer to the SDS, or take a sample
for analysis. There have been in-
HAZARDOUS CHEMICALS ON THE JOB MUST BE stances where workers were hurt
by tasting or smelling a material to
TRAINED TO PROTECT THEMSELVES (AND THEIR try to identify it.
7. Use materials only for their intend-
FAMILIES) FROM EXPOSURE TO THESE CHEMICALS.” ed purpose.
8. Don’t eat or drink while handling
carry contaminants home from sure it is in prime operating condi- hazardous materials.
work on your clothing. tion. 9. Be familiar with emergency pro-
3. Inspect containers to make sure cedures and equipment, including
A Dozen Additional they are properly labeled, that the evacuation procedures, emergency
Measures to Remember material in the container is appro- reporting procedures, and proce-
Although different types of chemi- priate for that container, and that dures for fires or spills.
cals require different handling, there the container is not damaged. If 10. Store all materials properly in
are some basic safety rules that ap- there are any indications other- ventilated, dry, cool areas.
ply to the handling of all hazardous wise, don’t use the material. 11. Separate incompatible materials.
chemicals. 4. Report damaged containers or il- 12.Clean work surfaces at least once
1. Be cautious and plan ahead. Know legible labels immediately. during a work shift to minimize
©ISTOCK.COM/MINERVA STUDIO
what could go wrong with the par- 5. Read the label and safety data sheet contamination risks.
ticular chemicals you are handling (SDS) before using any material so
and what you would do in case of that you understand the hazards Clare Condon is a contributing editor
an accident. and precautions to take. of Safety Decisions.
2. Always use the required PPE, and 6. If it is necessary to identify a ma- clarecondon@sbcglobal.net
inspect it before each use to make terial, make sure to read the label, Reprint: SD_0116-8
requirements (29 CFR 1904.39) went into effect in January 2015, the Agency has
been inundated with workplace incident reports. By Ana Ellington
A
nticipating a large in- Response Investigation (RRI). If an • Are employees still being exposed
crease in reports, OSHA RRI is deemed best, OSHA will send to the factors underlying the haz-
issued an internal en- the employer a letter requesting that ards that resulted in the injury
forcement memoran- the employer conduct an investiga- or illness?
dum on December 24, tion and report back to OSHA the • Was the incident the result of a
2014, to help the field root cause of the incident and the safety program failure, such as
offices manage these re- corrective actions that will be tak- permit-required confined spaces,
ports. It provides new procedures for en to prevent future incidents and lockout/tagout, or process safety
when to launch an inspection. protect employees. management?
The likelihood of an employer Under the memorandum, OSHA • Was the employee exposed to a
having to report a covered severe in- will triage each report into three cat- serious hazard (e.g., explosive
jury to OSHA is much higher under egories: materials, combustible dust, falls,
the new rule. Specifically, the revised 1. Category 1—Must be inspected. heat)?
standard requires employers to report • All fatalities and reports of two or • Were temporary workers or other
all work-related inpatient hospital- more inpatient hospitalizations; vulnerable populations injured or
izations, amputations, or losses of an • Any injury involving a worker un- made ill?
eye within 24 hours of the event. The der the age of 18; • Has another government agency
requirement to report any work-re- • Employers with a known history of (federal, state, or local) made a re-
lated fatality within 8 hours has not multiple injuries (same or similar ferral?
changed. The broad definitions for events in the previous 12 months); • Does the employer have a prior
inpatient hospitalization and ampu- • Employers considered repeat of- OSHA inspection history?
tation, which now includes fingertip fenders (history of egregious, will- • Is there a whistleblower complaint/
amputations with or without bone ful, failure-to-abate, or repeated inspection pending?
loss, probably contribute to the in- citations); • Is the employer a Cooperative Pro-
crease in workplace incidents reports. • Employers in the Severe Violator gram Participant (e.g., SHARP)?
According to OSHA, the Agency Enforcement Program; • Did the incident involve health is-
is averaging about 250 new reports • Injuries from hazards covered un- sues, such as chemical exposures
each week—taking up a great deal of der National Emphasis Programs or heat stress?
resources. or Local Emphasis Programs; and 3. Category 3—Reports will involve
When reporting an incident, the • Any report of imminent danger. situations where the majority of
following information is required: the responses to the Category 2
• Establishment name; If the reported incident does not questions were “No.” The field of-
• Location of the work-related inci- meet the criteria in Category 1, the fice will then likely initiate an RRI
dent; area director will have the discretion for Category 3 reports.
• Time of the work-related incident; to determine whether to conduct an
• Type of reportable event (e.g., fa- on-site inspection based on “yes” re- The procedures also create a new
tality, inpatient hospitalization, sponses to multiple questions. database that will capture all of the
amputation, or loss of an eye); 2. Category 2—The following list of information received from employers.
• Number and names of employees questions is not exhaustive, and OSHA has not said how these data
who suffered a fatality, inpatient other factors to particular inci- will be used or whether they will be
hospitalization, amputation, or loss dents may be considered. made available to the public.
of an eye;
• Contact person and his or her
phone number; and
• Brief description of the work-relat- “IF YOU RECEIVE A LETTER FROM YOUR
ed incident.
LOCAL OSHA OFFICE INITIATING AN RRI, YOU
The memorandum provides valu-
able insight into additional questions
MUST RESPOND WITHIN 5 WORKING DAYS TO
employers may be asked and outlines
the triage process field offices will
‘CONFIRM ABATEMENT AND STEPS THAT HAVE
use to sort through the data and to
determine whether to open an on-
BEEN TAKEN FOR ABATEMENT’ SO THAT THE
site inspection or to initiate a Rapid INCIDENT WILL NOT HAPPEN AGAIN.”
34 Safety Decisions | Winter/Spring 2016 SafetyDecisionsMagazine.com
being,” such as employee fatigue. Un-
safe and inappropriate employee and/
or manager behavior includes failing
to comply with the rules, taking short-
cuts, horseplay, failing to train, or fail-
ing to report hazards.
Root causes can include inade-
quate training, an outdated hazard
communication program, no inspec-
tion policy, or less-than-adequate
tools or equipment.
How do you find the root cause or
causes of an accident? By repeatedly
asking the question “Why?” (four or
five whys is a good rule of thumb),
you can peel away the layers of symp-
toms that can lead to the root cause of
an incident.
For example:
A worker is struck in the eye by a
flying object.
• Why? The machine had no guards
(surface cause).
• Why? The guards were removed
(surface cause).
• Why? To work faster (surface
cause).
• Why? Less-than-adequate train-
ing, procedures, and/or policies
(root causes).
RRI and Root Cause
Analysis “THE LIKELIHOOD You can use Safety.BLR.com’s inci-
If you receive a letter from your lo-
cal OSHA office initiating an RRI, OF AN EMPLOYER dent analysis tool to help complete a
root cause analysis of an incident.
you must respond within 5 working
days to “confirm abatement and steps
HAVING TO REPORT Just the Facts
that have been taken for abatement”
so that the incident will not happen
TO OSHA A COVERED When completing the RRI report for
OSHA, state the known facts, not
again—an extension can be requested SEVERE INJURY IS your opinion or speculation. Under-
for complicated events. stand that root causes identified in
OSHA’s written letter requires that MUCH HIGHER UNDER an employer’s report can amount to
you provide it with the results of an
investigation into the incident that THE NEW RULE.” an admission of a violation, such as
failure to conduct required training or
documents findings and corrective repair a faulty safety device. Be careful
actions taken. The goal of the investi- which always preexist surface causes. because your responses can be used
gation is to identify the immediate or Surface causes are hazardous con- against you by OSHA. As such, sim-
contributing causes (known as surface ditions and unsafe or inappropriate ply respond with conclusions to your
causes) and the underlying causes (or behaviors that are the direct cause of investigation and corrective actions
©ISTOCK.COM/MICHAELJUNG
root causes) of the incident. Accord- the incident. that have been taken to ensure that no
ing to OSHA, you can usually trace Hazardous conditions include de- future incidents will occur.
surface causes to inadequate or weak fective or unsafe equipment; defects
safety systems, such as policies, pro- in processes or procedures such as Ana Ellington is a contributing editor of
grams, plans, processes, procedures, unguarded machines, a ladder in dis- Safety Decisions. aellington@blr.com
or practices. These are the root causes, repair, or slippery roads; or “states of Reprint: SD_0116-9
©ISTOCK.COM/KIMTARO
What Is Machine dards can be a challenging step in onto the American National Stan-
Guarding? reducing risks in the workplace. Al- dard Institute’s (ANSI) standards on
Machine guarding is used as a precau- though the requirements for machine machine safety. ANSI standard ANSI
tionary safety feature on machinery and and employee safety may seem end- B11.19-2010, The Performance Crite-
other pieces of equipment. It is a shield less, there are ways to ensure proper ria for Safeguarding, provides valuable
or device protecting body parts from ac- safeguarding for employees. OSHA guidance on the design, construction,
installation, operation, and mainte- focused on the end users, since they equipment, who is responsible for the
nance of the guarding systems used are typically the ones that have em- guarding, and how a facility can com-
to protect employees from potential ployees at the point of operations ply with guarding requirements while
machine hazards. where hazards could exist. maintaining efficient productivity
With the understanding of what is There is some responsibility on and employee safety. There are four
expected of machine guarding equip- the side of the OEM, however. While main factors that contribute to this
ment and the regulations that are to the OEM is typically unsure of the fi- confusion.
serve as the guidelines for safeguard- nal location and process staging that
ing practices, probably the most con- the employer has designated for the 1. Multiple Functions
fusing aspect is that the same machine equipment, the OEM should con- Machine guarding often relies heav-
could pose different hazards and could sider any foreseeable use and mis- ily on these safeguards to perform
require different guarding depending use of the equipment, as well as the multiple functions. These safeguards
on its placement within a facility and potential point of operation hazards are expected to not only prevent the
depending on how and where in the for those who may come in contact accidental contact with hazards and
process the equipment is used. with the equipment. Also, the OEM’s moving equipment but they are also
As outlined in the ANSI standard, risk assessment should be provided expected to be easily removed and
it is the role of both the OEM and the with all new equipment the way that secured for maintenance, to protect
end user to conduct a risk assessment a safety data sheet (SDS) is provid- the equipment from falling objects
in order to determine the safeguard- ed with chemicals. This assessment or other moving equipment, and to
ing that is required for the equip- will allow the end user to examine not create any additional hazards. Of
ment. One thing to consider about the to what depth the potential risks and course, another significant goal is that
OEM’s risk assessment is that it is im- hazards were identified and mitigat- the safeguards don’t prevent an oper-
practical to expect a machine designer ed by the OEM, as well as what gaps ator from performing his or her job
to foresee all potential hazards associ- are present. efficiently and effectively.
ated with equipment setup, operation,
maintenance, and placement within a What Makes Machine 2. Failure to Assess Risk
facility. The end user should conduct Guarding So Difficult? As stated in ANSI B11.0-2010, Safety
a risk assessment separate from that Despite OEMs becoming increasing- of Machinery—General Requirements
of the OEM as a part of due diligence ly aware of the importance of ma- and Risk Assessment, Section 4.6:
for recognizing and reducing risk. The chine guarding—whether it be from
end user is the most knowledgeable a productivity, safety, compliance, or “The supplier shall provide safeguard-
party for interpreting how the equip- even an aesthetic standpoint—ma- ing as determined in the supplier risk
ment will be used, where it will be chine guarding continues to place on assessment and the appropriate ma-
stored, and where the operators will OSHA’s top 10 most frequently cited chine-specific standard. The user shall
be in contact with potential hazards standards3. This ranking demon- ensure that additional safeguarding is
based on the process the equipment is strates that there is still confusion on provided and installed as determined
involved in. what is required to properly safeguard in the user risk assessment.”
According to OSHA’s General Duty
Clause, the employer has an obliga-
tion to protect workers from serious
and recognized workplace hazards
even where there is no standard. Em-
ployers must take whatever abatement
“WHILE THERE ARE COUNTLESS
actions are feasible to eliminate these
hazards. Based on this, it is not stan-
EXAMPLES OF FACILITY PERSONNEL
dard practice for OSHA to inspect a CONSTRUCTING MAGNIFICENT
machine manufactured by the OEM
prior to being set up in the end user’s SAFEGUARDS, MACHINE GUARDING
facility. Instead, an OSHA inspector
will inspect the equipment being used REMAINS ONE OF THE MOST CITED
for the manufacturing process, work
practices within the organization,
REGULATIONS DURING OSHA INSPECTIONS.”
and the facility. Practically all OSHA
enforcement for machine safety is
In many cases, employers can find sometimes be misled by OEMs or ma- but they were not mitigated, abated,
it difficult to assess risk as they take chine sales representatives. The phras- or somehow guarded due to difficul-
the OEMs’ word for it that the equip- es “OSHA compliant” and “meets all ty of guarding applications or because
ment is properly guarded, or the em- OSHA requirements” have been mis- it is simply too expensive, they could
ployer does not possess the expertise used by OEMs and machine sales rep- be considered willful violations by
to conduct a proper risk assessment resentatives in order to sell equipment OSHA and any associated fines could
to ensure safety and compliance. to employers who honestly may not increase exponentially.
Conducting a risk assessment of new know any better. OSHA does not cer-
equipment is not only required, it is tify equipment to be “compliant.” In Solutions
a great method of due diligence for fact, that idea helped start the path to- The solutions to the problems that I
determining the risks present for that ward the creation of this investigation have discussed in this article are not
piece of equipment as well as for that and the compilation of this article. simple. The knowledge, ability, and
section of the process. Guards are de- If an OEM claims that a piece of confidence to perform a risk assess-
signed and installed to protect against equipment is “OSHA compliant” ment on equipment is by no means
identified hazards. If hazards are not or that it “meets all OSHA require- easy. One has to keep in mind the
identified, then it is unlikely they will ments,” as seen in the example above, potential risks present on the piece
be protected against. you should first obtain any risk as- of equipment as well as understand
If an employer is unsure about sessments that have been conducted that employees do make mistakes,
the risk assessment process or the on that equipment and check for any and the potential for serious injury
risk assessment itself, there are a few Underwriters Laboratory (UL) or Na- is always present. For these reasons,
options. The employer can contact a tional Institute for Occupational Safe- it can be extremely beneficial to em-
third party or a consultant to come ty and Health (NIOSH) stamps on the ploy or cooperate with a third-party
on-site and conduct a risk assessment equipment. Those types of markings specialist.
in accordance with the standards, the will help indicate that the equipment Specialists include machine de-
employer can have the maintenance has at least undergone a safety in- signers, maintenance personnel,
staff or other employees conduct a spection by a reliable agency. Another consultants, and OSHA compli-
HTTP://WWW.MCMASTER.COM/#BENCH-GRINDERS/=ZU2ENP]
risk assessment, or the employer can thing to keep in mind is that regula- ance assistance specialists. While a
contact OSHA’s compliance assistance tions vary between different coun- third-party specialist will cost the
specialists. Whichever method is cho- tries, and any equipment that is con- facility a bit, machine guarding spe-
sen, it is a good practice to obtain structed outside of the United States cialists and safety consultants can
and review the original manufactur- should be purchased with caution, often find several potential viola-
er’s risk assessment and maintain it and a separate risk assessment should tions and potential hazards from
with the records for that equipment. be conducted. inadequate machine safeguarding
The OEM’s risk assessment should be techniques, standards, and practices
made available upon request. 4. Cost and Difficulty that many maintenance personnel
of Solutions may overlook. One thing that a con-
3. Misleading OEM Labels Any risk that is identified should be sultant is particularly good at is the
Along with the intricate principles mitigated to ensure a safe workplace. If ability to not simply focus on OSHA
of machine safety, employers can there are hazards present and identified, standards—they are able to use their
Practical Tips
28 If the Shoe Fits—
Don’t Charge for It!
Ensuring employees have the tools to
perform their jobs safely should be a
win-win for both worker and employer. But,
you need to consider all aspects of your
safety program—or you might get sued.
By Jasmin Rojas, JD
Reprint: SD_Quarter-7
Day to Day
over LOTO Compliance 33 Understanding OSHA’s
Procedures When Reporting
Update your understanding of this life- and limb-saving standard. By Evelyn Sacks
Reprint: SD_0116-2 Severe Injuries and RRIs
Since the Occupational Safety and Health
Administration’s (OSHA) new reporting
requirements (29 CFR 1904.39) went into
DEPARTMENTS 20 Why Safety Culture Is More effect in January 2015, the Agency has
Important Than You Think been inundated with workplace
incident reports.
Keeping Up Safety should be universal, but many
organizations find themselves falling short. By Ana Ellington
6 EOSHA Penalties Up … Counting The key difference? A clear and consistent Reprint: SD_Quarter-9
Inspections … Aging Workforce … Sitting safety culture.
Isn’t So Bad … Opioid Painkillers … Tracking By Jim Holland 36 ‘But It Came That Way’—
Toxic Exposure … Quick Reminder … Reprint: SD_0116-4 The Roles, Responsibilities, and
Cal/OSHA and Healthcare Violence …
AIHA Mold Resource … Ergo Shovels … Accountability of Machine Guarding
Reprint: SD_0116-1
22 Incentivizing Safety: How Each year, more than 200,000 workers
Companies Are Linking CEO suffer cuts, lacerations, and amputations
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